C&F: 2888417.1 i C&F: 1059252.1 BLUE SKY TOWERS, LLC (“BLUE SKY”) AND NEW CINGULAR WIRELESS PCS, LLC (AT&T) For a Certificate of Environmental Compatibility and Public Need —EVERGREEN STREET FACILITY— Blue Sky Towers, LLC (“Blue Sky”) 158 Main Street, Suite 2 Norfolk, MA 02056 New Cingular Wireless PCS, LLC (“AT&T”) 500 Enterprise Drive Rocky Hill, CT 06067
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BLUE SKY TOWERS, LLC (“BLUE SKY”) AND NEW CINGULAR … · the City zoned I-L (Industrial) with existing access from Evergreen Street. Blue Sky Towers, LLC (“Blue Sky”) has
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C&F: 2888417.1 i C&F: 1059252.1
BLUE SKY TOWERS, LLC (“BLUE SKY”)
AND
NEW CINGULAR WIRELESS PCS, LLC (AT&T)
For a Certificate of
Environmental Compatibility and Public Need
—EVERGREEN STREET FACILITY—
Blue Sky Towers, LLC (“Blue Sky”)
158 Main Street, Suite 2
Norfolk, MA 02056
New Cingular Wireless PCS, LLC (“AT&T”)
500 Enterprise Drive
Rocky Hill, CT 06067
C&F: 2888417.1
Table of Contents ii
Table of Contents
Page
Table of Contents ...................................................................................................... i
I. Introduction ...................................................................................................... 1
A. Purpose and Authority ..................................................................................... 1
B. Executive Summary ......................................................................................... 1
C. The Applicants ................................................................................................. 4
D. Application Fee ................................................................................................ 5
E. Compliance with C.G.S. §16-50l (c)............................................................... 5
II. Service and Notice Required by C.G.S. § 16-50l (b) ................................ 5
III. Statements of Need and Benefits ................................................................ 6
A. Statement of Need .......................................................................................... 6
B. Statement of Benefits .................................................................................... 11
C. Technological Alternatives ............................................................................. 12
IV. Site Selection and Tower Sharing ............................................................. 12
A. Site Selection ................................................................................................. 13
B. Tower Sharing ............................................................................................... 13
V. Facility Design .............................................................................................. 13
VI. Environmental Effects .................................................................................. 15
A. Visual Assessment......................................................................................... 15
B. CT DEEP, SHPO and Other State and Federal Agency Comments ........ 16
C. Power Density ................................................................................................ 16
D. Wetlands, Drainage & Other Environmental Factors .................................. 16
E. National Environmental Policy Act Review .................................................. 17
VII. Consistency with the City of Bridgeport's Land Use Regulations.......... 17
A. Bridgeport's Plan of Conservation and Development .................................. 18
C&F: 2888417.1
Table of Contents iii
B. Bridgeport’s Zoning Regulations and Zoning Classification ........................ 18
C. Planned and Existing Land Uses ................................................................. 18
D. Bridgeport’s Inland Wetlands and Watercourses Regulations .................... 18
VIII. Consultation with City Officials ................................................................... 18
IX. Estimated Cost and Schedule .................................................................... 19
A. Overall Estimated Cost ................................................................................. 19
B. Overall Scheduling ......................................................................................... 20
1. AT&T’s Statement of Radio Frequency (RF) Need with Coverage Plots
2. Summary of Site Search and List of Existing Tower/Cell Sites
3. Site and Facility Description
4. Aerial Map, Topographical Map, Drawings and FAA Determination
5. Environmental Assessment Statement
6. National Wetland Inventory Map and FEMA Flood Map
7. Power Density Analysis
8. Visibility Analysis
9. CT Department of Energy and Environmental Protection (DEEP) NDDB
Correspondence
10. State Historic Preservation Office (SHPO) Correspondence
11. Correspondence related to municipal consultations
12. Text of legal notice published in The Connecticut Post; Notice to Abutting
Landowners; List of Abutting Landowners; Certification of Service of Notice
13. Certification of Service of Application on Federal, State and Municipal Agencies
14. Connecticut Siting Council Application Guide
C&F: 2888417.1
Introduction 1
I. Introduction
A. Purpose and Authority
Pursuant to Chapter 277a, § 16-50g et seq. of the Connecticut General Statutes
(C.G.S.), as amended, and § 16-50j-1 et seq. of the Regulations of Connecticut State
Agencies (R.C.S.A.), as amended, Blue Sky Towers, LLC (“Blue Sky”) and New
Cingular Wireless PCS, LLC (“AT&T”) hereby submit an application and supporting
documentation (collectively, the “Applicants”) for a Certificate of Environmental
Compatibility and Public Need for the construction, maintenance and operation of a
telecommunications tower facility (the “Facility”). The Facility is proposed on a 1 acre
parcel of land owned by Chapin & Bangs Company (the “Parcel”) with an address of
220 Evergreen Street in the City of Bridgeport. The Parcel is undeveloped, zoned I-L
(Industrial) and is currently used as part of a steel fabrication business. A tower is
proposed in conjunction with other existing and proposed facilities, in order to allow
AT&T and other FCC licensed wireless carriers to provide their services in this area of
Bridgeport as part of relocating existing wireless facilities at 370 North Avenue (“HI HO
Facility”). Of note, the proposed replacement tower would be in the same location as
a temporary tower facility on the same property, which was approved by the
Connecticut Siting Council in Petition No. 1169.
B. Executive Summary
The proposed tower Facility at 220 Evergreen Street in Bridgeport is needed in
conjunction with other existing and proposed facilities in order for AT&T to replace
service in this part of the state after the HI HO Facility is decommissioned. AT&T,
and its affiliates, have operated a wireless facility at the HI HO Facility for
approximately 10 years. AT&T’s Facility at that location was originally approved by
the City of Bridgeport. Sprint and Verizon also operate wireless facilities at the HI HO
Facility. There are four (4) silos, a bridge and a steel structure (collectively the
“support structure”) that make up the HI HO Facility. Due to the excessive structural
deterioration of the existing support structure on which AT&T’s antennas are located,
the entire structure was deemed a hazard to any technicians, tower hands, or anyone
else working on or around this structure. Additionally, AT&T radiofrequency
engineering was unable to add proposed LTE capacity to its existing facility at the HI
HO Facility and AT&T network operations would not restore service from the site in
C&F: 2888417.1
Introduction 2
the event of an outage due to the existing site conditions. Accordingly, it was
recommended that AT&T relocate its antennas from the HI HO Facility.
The relocation site search was conducted by Blue Sky and AT&T based on two
principal factors: 1) the need to replicate as much coverage as possible from the HI
HO Facility to be decommissioned; and 2) construction of a facility in the vicinity of
this industrial and commercial part of Bridgeport. A review of other communications
towers and facilities within proximity to the HI HO Facility and the geographic area
within AT&T’s surrounding sites in Bridgeport indicated that none would provide
adequate replacement coverage. Based on the location of the HI HO Facility and
coverage objectives, the search area focused on the industrially zoned areas of
Bridgeport in close proximity. Of all the sites evaluated, the 220 Evergreen Street site
location was deemed by Blue Sky and AT&T to best meet technical service
requirements, be legally available for a tower, and otherwise minimize environmental
effects to the extent practicable. Other locations evaluated, were either legally
unavailable for tower siting, technically inadequate to satisfy coverage requirements in
this part of the state or determined by the Applicants to have comparatively greater
overall environmental effects.
Due to the time required for permitting, construction and operation of a permanent
replacement site for the HI HO Facility, AT&T coordinated with Blue Sky for the
development of a temporary tower at 220 Evergreen Street to allow for more
immediate relocation from the existing HI HO Facility. On July 2, 2015, AT&T filed a
Petition for a Temporary Tower at 220 Evergreen Street. The temporary tower is an
interim measure which was intended to address the existing HI HO Facility safety and
wireless network issues AT&T was experiencing and while a permanent site can be
approved, constructed and integrated into AT&T’s wireless network. A copy of the
Council’s approval for the temporary tower in Petition 1169 is included in Attachment
1. The temporary facility is in the construction phase as of the time of this filing.
On August 28, 2015, AT&T filed a technical report with the City of Bridgeport for the
permanent replacement tower at 220 Evergreen Street commencing the 16-50l
consultation. After discussions with City staff in Bridgeport, we were advised that the
City did not require further consultation or a public information session in advance of a
C&F: 2888417.1
Introduction 3
CSC application. Attachment 11 contains a letter from the City of Bridgeport noting its
opinion that the underlying parcel is suitable for a tower site.
The tower as proposed would replace the existing temporary tower, as approved in
Petition 1169, at 220 Evergreen Street. The property consists of an approximately 1
acre parcel (“Lot 2”), owned by Chapin & Bangs Company, which owns an adjoining
parcel and is used as part of its steel fabrication services. The lot is in an area of
the City zoned I-L (Industrial) with existing access from Evergreen Street. Blue Sky
Towers, LLC (“Blue Sky”) has entered into a lease with Chapin & Bangs Company
and AT&T has entered into an agreement with Blue Sky for construction of a
permanent replacement tower facility on the Parcel which would be owned by Blue
Sky. AT&T would install and operate its wireless facility on the replacement tower at
the site. Blue Sky anticipates that Sprint and Verizon could relocate their facilities to
the replacement tower in the future.
The replacement tower is proposed as a new self-supporting monopole 135’ in height
which is slightly taller than the existing 128’ temporary tower on site. AT&T would
install up to twelve (12) panel antennas and related equipment at a centerline height
of 130’ above grade level (AGL) on the replacement tower. The tower would be
designed for future shared use of the structure by two additional FCC licensed
wireless carriers. AT&T would install a permanent 12’ x 20’ equipment shelter within
the existing 3,617.5 s.f. tower compound on site. The existing tower compound would
remain the same, as approved in Petition 1169, enclosed by an 8’ high chain link
fence and would accommodate for future shared use of the facility by other carriers
who will likely also relocate here from the HI HO Facility. Vehicle access to the
facility exists over a 15’ wide access easement with a gate on Evergreen Street.
Utility connections are routed overhead from an existing utility pole located along
Evergreen Street. The facility will be unmanned with no sanitary or water services
and generates on average 1 vehicle trip per month by each wireless carrier consisting
of a service technician in a light duty van or truck.
The Applicants respectfully submit that the public need for a replacement tower in this
area of Bridgeport outweighs the environmental effects from the Facility as proposed.
For reference as part of the application process, visibility can be compared relative to
the temporary tower which would be removed as part of siting the replacement tower.
C&F: 2888417.1
Introduction 4
Other environmental effects have been minimized by the Applicants’ selection of a
tower site location on a property within a dense industrial and commercial area of the
City. Relative to need, AT&T’s analysis indicates that there are several thousand
people who live in the area currently served by 3G and 4G LTE. As proposed, the
replacement Facility will enable AT&T to continue to provide a substantial portion of
the service that would be lost in the subject area as a result of the decommissioning
of the HI HO Facility.
C. The Applicants
The Applicant Blue Sky Towers, LLC is a Delaware limited liability company with its
headquarters at 352 Park Street Suite 106, North Reading, Massachusetts. Blue Sky
develops/builds, owns and leases numerous communications towers in the United
States. Blue Sky entered into a long term lease with Chapin & Bangs Company and
subsequently, a lease with AT&T. Blue Sky will construct, maintain and own the
proposed Facility and would be the Certificate holder.
Applicant AT&T is a Delaware limited liability company with an office at 500 Enterprise
Drive, Rocky Hill, Connecticut 06067. The company’s member corporation is licensed
by the Federal Communications Commission (“FCC”) to construct and operate a
personal wireless services system, which has been interpreted as a “cellular system”,
within the meaning of C.G.S. Section 16-50i(a)(6).
Neither company conducts any other business in the State of Connecticut other than
the development of tower sites and provision of personal wireless services under FCC
rules and regulations. Correspondence and/or communications regarding this
Application shall be addressed to the attorneys for the Applicants:
Cuddy & Feder LLP
445 Hamilton Avenue, 14th Floor
White Plains, New York 10601
Attention: Christopher B. Fisher, Esq.
Daniel M. Laub, Esq.
A copy of all correspondence shall also be sent to:
C&F: 2888417.1
II. Service and Notice Required by C.G.S. § 16-50l (b) 5
Blue Sky Towers, LLC
352 Park Street Suite 106
North Reading, Massachusetts 01864
Attention: Sean Gormley
AT&T
500 Enterprise Drive
Rocky Hill, CT 06067
Attention: Michele Briggs
D. Application Fee
Pursuant to R.C.S.A. § 16-50v-1a (b), a check made payable to the Siting Council in
the amount of $1,250 accompanies this Application. Included in this Application and
its accompanying attachments are reports, plans and visual materials detailing the
design and location for the proposed Facility and the environmental effects associated
therewith. A copy of the Siting Council’s Community Antennas Television and
Telecommunication Facilities Application Guide with page references from this
Application is also included in Attachment 14.
E. Compliance with C.G.S. §16-50l (c)
Neither of the Applicants is engaged in generating electric power in the State of
Connecticut. Therefore, the Facility is not subject to C.G.S. § 16-50r. Furthermore,
the proposed Facility has not been identified in any annual forecast reports.
Accordingly, the proposed Facility is not subject to § 16-50l (c).
II. Service and Notice Required by C.G.S. § 16-50l (b)
Pursuant to C.G.S. § 16-50l (b), copies of this Application have been sent by certified
mail, return receipt requested, to municipal, regional, state, and federal officials. A
certificate of service, along with a list of the parties served with a copy of the
Application is included in Attachment 13. Pursuant to C.G.S. § 16-50l (b), notice of
the Applicant’s intent to submit this application was published on two occasions in The
Connecticut Post. The text of the published legal notice is included in Attachment 12.
The original affidavits of publication will be provided to the Siting Council once
C&F: 2888417.1
III. Statements of Need and Benefits 6
received from the publisher. Furthermore, in compliance with C.G.S. § 16-50l (b),
notices were sent to each person or entity appearing of record as the owner of a
property which abuts the premises on which the Facility is proposed. Certification of
such notice, a sample notice letter, and the list of property owners to whom the notice
was mailed are also included in Attachment 12.
III. Statements of Need and Benefits
A. Statement of Need
1. United States Policy & Law – Wireless Facilities
United States policy and laws support the growth of wireless networks. In 1996, the
United States Congress recognized the important public need for high quality wireless
communications service throughout the United States in part through adoption of the
Telecommunications Act (the “Act”). A core purpose of the Act was to “provide for a
competitive, deregulatory national policy framework designed to accelerate rapidly
private sector deployment of advanced telecommunications and information technologies
to all Americans.” H.R. Rep. No. 104-458, at 206 (1996) (Conf. Rep.). With respect
to wireless communications services, the Act expressly preserved state and/or local
land use authority over wireless facilities, placed several requirements and legal
limitations on the exercise of such authority, and preempted state or local regulatory
oversight in the area of emissions as more fully set forth in 47 U.S.C. § 332(c)(7). In
essence, Congress struck a balance between legitimate areas of state and/or local
regulatory control over wireless infrastructure and the public’s interest in its timely
deployment to meet the public need for wireless services.
Nineteen years later, it remains clear that the current White House administration, The
Congress and the FCC continue to take a strong stance and act in favor of the
provision of wireless service to all Americans. In December 2009, the President
issued Proclamation 8460 which included wireless facilities within his definition of the
nation’s critical infrastructure and declared in part:
Critical infrastructure protection is an essential element of a resilient and
secure nation. Critical infrastructure are the assets, systems, and
networks, whether physical or virtual, so vital to the United States that
their incapacitation or destruction would have a debilitating effect on
C&F: 2888417.1
III. Statements of Need and Benefits 7
security, national economic security, public health or safety. From water
systems to computer networks, power grids to cellular phone towers,
risks to critical infrastructure can result from a complex combination of
threats and hazards, including terrorist attacks, accidents, and natural
disasters.1
The President further identified the role of robust mobile broadband networks in his
2011 State of the Union address.2 In 2009, The Congress directed the FCC to
develop a national broadband plan to ensure that every American would have access
to “broadband capability” whether by wire or wireless. What resulted in 2010 is a
document entitled “Connecting America: The National Broadband Plan” (the “Plan”).3
Although broad in scope, the Plan’s goal is undeniably clear:
[A]dvance consumer welfare, civic participation, public safety and
homeland security, community development, health care delivery, energy
independence and efficiency, education, employee training, private sector
investment, entrepreneurial activity, job creation and economic growth,
and other national purposes.4 [internal quotes omitted]
The Plan notes that wireless broadband access is growing rapidly with “the emergence
of broad new classes of connected devices and the rollout of fourth-generation (4G)
wireless technologies such as Long Term Evolution (LTE) and WiMAX.”5 A specific
goal of the Plan is that “[t]he United States should lead the world in mobile innovation,
with the fastest and most extensive wireless networks of any nation.” 6
In April 2011, the FCC issued a Notice of Inquiry concerning the best practices
available to achieve wide-reaching broadband capabilities across the nation including
1 Presidential Proclamation No. 8460, 74 C.F.R. 234 (2009). 2 Cong. Rec. H459 (Jan. 25, 2011), also available at http://www.whitehouse.gov/the-press-office/2011/01/25/ remarks-
president-state-union-address. Specifically the President stressed that in order “[t]o attract new businesses to our
shores, we need the fastest, most reliable ways to move people, goods, and information—from high-speed rail to high-
speed Internet.” 3 Connecting America: The National Broadband Plan, Federal Communications Commission (2010), available at
http://www.broadband.gov/plan/. 4 Id. at XI. 5 Id. at 76. 6 Id. at 25.
C&F: 2888417.1
III. Statements of Need and Benefits 8
better wireless access for the public.7 The public need for timely deployment of
wireless infrastructure is further supported by the FCC’s Declaratory Ruling interpreting
§ 332(c)(7)(B) of the Telecommunications Act and establishing specific time limits for
decisions on land use and zoning permit applications.8 More recently, the critical
importance of timely deployment of wireless infrastructure to American safety and
economy was confirmed in the Middle Class Tax Relief and Job Creation Act of 2012,
which included a provision, Section 6409, that together with 2015 FCC regulations,
preempts a discretionary review process for eligible modifications of existing wireless
towers or base stations.9
2. United States Wireless Usage Statistics
Over the past thirty years, wireless communications have revolutionized the way
Americans live, work and play.10 The ability to connect with one another in a mobile
environment has proven essential to the public’s health, safety and welfare. As of
June 2013, there were an estimated 336 million wireless subscribers in the United
States.11 Wireless network data traffic was reported at 3.2 trillion megabytes, which
represents a 723% increase from 2010.12 Other statistics provide an important
sociological understanding of how critical access to wireless services has become. In
2005, 8.4% of households in the United States had cut the cord and were wireless
only.13 By December 2014, that number grew exponentially to an astonishing 44% of
7 FCC 11-51: Notice of Inquiry, In the Matter of Acceleration of Broadband Deployment: Expanding the Reach and
Reducing the Cost of Broadband Deployment by Improving Policies Regarding Public Rights of Way and Wireless
Facilities Siting, available at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0407/FCC-11-51A1.pdf. 8 WT Docket No. 08-165- Declaratory Ruling on Petition for Declaratory Ruling to Clarify Provisions of Section
332(c)(7)(B) to Ensure Timely Siting Review and to Preempt Under Section 253 State and Local Ordinances that
Classify All Wireless Siting Proposals as Requiring a Variance (“Declaratory Ruling”). 9 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, §6409 (2012), available at
http://gpo.gov/fdsys/pkg/BILLS-112hr3630enr/pdf/BILLS-112hr3630enr.pdf; see also H.R. Rep. No. 112-399 at 132-33
(2012)(Conf. Rep.), available at http://www.gpo.gov/fdsys/pkg/CRPT-112hrpt399/pdf/CRPT-112hrt399.pdf. 10 See, generally, History of Wireless Communications, available at http://www.ctia.org/media/industry_
info/index.cfm/AID/10388 (2011) 11 CTIA’s Wireless Industry Indices: Semi-Annual Data Survey Results, A Comprehensive Report from CTIA Analyzing
the U.S. Wireless Industry, Mid-Year 2013 Results (Semi-Annual Data Survey Results). See also, “CTIA’s Annual
Survey Says US Wireless Providers Handled 3.2 Trillion Megabytes of Data Traffic in 2013 for a 120 Percent Increase
Over 2012” available at http://www.ctia.org/resource-library/press-releases/archive/ctia-annual-survey-2013. 12 Id. 13 CTIA Wireless Quick Facts, available at http://www.ctia.org/your-wireless-life/how-wireless-works/wireless-quick-facts
citing Early Release of Estimates from the National Health Interview Survey, December 2012, National Center for
Health Statistics, June 2013.
C&F: 2888417.1
III. Statements of Need and Benefits 9
all households.14 Connecticut in contrast lags behind in this statistic with 20.6%
wireless only households.15
Wireless access has also provided individuals a newfound form of safety. Today,
approximately 70% of all 9-1-1 calls made each year come from a wireless device.16
Beginning May 15, 2014, wireless carriers in the U.S. voluntarily supported Text-to-911,
a program that allows users to send text messages to emergency services as an
alternative to placing a phone call. AT&T and other licensed FCC wireless carriers will
support Text-to-911.17 Parents and teens have also benefited from access to wireless
service. In a 2010 study conducted by Pew Internet Research, 78% of teens
responded that they felt safer when they had access to their cell phone.18 In the
same study, 98% of parents of children who owned cell phones stated that the main
reason they have allowed their children access to a wireless device is for the safety
and protection that these devices offer.19
Wireless access to the internet has also grown exponentially since the advent of the
truly “smartphone” device. Cisco reports that in 2014 global mobile data traffic grew
69 percent reaching 2.5 exabytes a month.20 Notably, mobile data traffic in 2014 was
nearly 30 times the size of the entire global internet in 2000; specifically, one exabyte
of traffic traversed the global Internet in 2000 and in 2014 mobile networks carried
14 Stephen J. Blumberg, Ph.D., and Julian V. Luke, Division of Health Interview Statistics, National Center for Health
Statistics, “Wireless Substitution: Early Release of Estimates From the National Health Interview Survey, January – June
2014”, released December 12, 2014 and available at http://www.cdc.gov/nchs/data/nhis/earlyrelease/wireless201412.pdf. 15 Early Release of Estimates from the National Health Interview Survey, December 2012, National Center for Health
Statistics, June 2013. See also, “Wireless Substitution: State-level Estimates From the National Health interview
Survey, 2012”, National Health Statistics Report, No. 70, December 18, 2013. 16 Wireless 911 Services, FCC, available at http://www.fcc.gov/guides/wireless-911-services
17 See Text-to-911: What you need to know (FAQ) available at http://www.cnet.com/news/text-to-911-what-you-need-to-
know-faq. It should be noted that while the carriers have committed to supporting 911 texting in their service areas,
text-to-911 will not be available everywhere. Emergency call centers, called PSAPs (Public Safety Answering Points),
are the bodies in charge of implementing text messaging in their areas. These PSAPs are under the jurisdiction of their
local states and counties, not the FCC, which governs the carriers. See also, What You Need to Know About Text-to-
911 available at www.fcc.gov/text-to-911. At the time of writing there are no known areas in Connecticut that yet
support Text-to-911, see https://transition.fcc.gov/pshs/911/Text911PSAP/Text_911_Master_PSAP_Registry.xlsx. 18 Amanda Lenhart, Attitudes Towards Cell Phones, Pew Research, available at
Attachment 4: 3D Terrain Map ..................................................................................................................................................... 9
Attachment 5: Map of Distance to Neighbor Sites – Bridgeport ......................................................................................... 10
Attachment 6: Neighbor Site Data and Distance to Proposed Site ..................................................................................... 11
Attachment 11: Connecticut DOT Average Annual Daily Traffic Data – Bridgeport ................................................... 16
C Squared Systems, LLC i September 28, 2015
AT&T CT5991
1. Overview
C Squared Systems was retained by New Cingular Wireless PCS, LLC (“AT&T”) to investigate the extent of coverage loss resulting from the scheduled decommissioning of the 370 North Avenue site (CT5092), herein referred to as the “Decom” site and the extent of coverage that could be potentially be recovered by deploying the proposed wireless communications facility at 220 Evergreen Street in Bridgeport, referred to herein as the Proposed Site (designated on the attached plots as CT5100). The Proposed Site will have an overall height of 135 feet AGL.
AT&T is licensed by the FCC to provide wireless communications services throughout the State of Connecticut including the Town of Bridgeport where the proposed facility would be located.
This report addresses AT&T’s need for the Proposed wireless facility and confirms that there are no other suitable existing structures capable of providing the coverage lost with the decommissioning of the 370 North Avenue site. The coverage analysis completed by C Squared Systems confirms that one; decommissioning AT&T’s existing site CT5092 will create a significant gap and loss of reliable AT&T service in Bridgeport and that two; the proposed site will provide AT&T with a coverage solution throughout a substantial portion of the subject area impacted by the decommissioning of CT5092.
Included as attachments to this report are coverage maps detailing the existing 3G UMTS network and predicted 3G coverage from the proposed facility, pertinent site information, terrain and network layout maps, along with the 4G LTE deployment coverage.
2. Technology Advances & Design Evolution
AT&T provides digital voice and data services using 3rd Generation (3G) UMTS technology in the 800 MHz and 1900 MHz frequency band, and is in the midst of deploying advanced 4th Generation (4G) services over LTE technology in the 700 MHz and 1900 MHz frequency bands as allocated by the FCC. As part of their network expansion and ongoing technology advancements in Connecticut and elsewhere in the Country, the 4G LTE network rollout will build on the existing 3G data services that utilize UMTS technology. These data networks are used by mobile devices for fast web browsing, media streaming, and other applications that require broadband connections. The mobile devices that benefit from these advanced data networks are not limited to basic handheld phones, but also include devices such as smartphones, PDA’s, tablets, and laptop air-cards. With the evolving rollout of 4G LTE services and devices, AT&T customers will have even faster connections to people, information, and entertainment.
It is important to note that with AT&T’s migration from 3G to 4G services come changes in the base station infrastructure and resultant changes in the operating thresholds required by the LTE network. In the past, AT&T has presented receive signal thresholds of -74 dBm for their in-building coverage threshold and -82 dBm for their in-vehicle coverage threshold. Those thresholds were based on network requirements to support 2G/3G data speeds and past usage demand. Today, customers expect low latency and faster data speeds as evidenced by increasing data usage trends and customer demand.
AT&T’s 4G LTE technology is designed to thresholds of -83 dBm and -93 dBm for their 700 MHz LTE and -86 dBm and -96 dBm for their 1900 MHz LTE.1 The stronger thresholds (-83 dBm and -86 dBm) yield greater throughputs
1 The threshold range differences between the 700 MHz and 1900 MHz frequency bands directly correlates to the type branch diversity receivers deployed in AT&T’s receiver design.
C Squared Systems, LLC 1 September 28, 2015
AT&T CT5991
and improved customer experience. The -93 dBm and -96 dBm thresholds are the minimum acceptable levels required to meet customer expectations for 4G service.
3. Coverage Objective
The Decommissioning of the 370 North Avenue Site would significantly increase the coverage deficiency in the existing AT&T wireless communications network in the town of Bridgeport, CT. This coverage deficiency includes but is not limited to the following:
• State Highway 8, State Highway 127, Route 1;
• Main Street, Capitol Avenue, Lindley Street;
• Island Brook Avenue, Noble Avenue, Huntington Road;
• The commercial and residential neighborhoods in the vicinity of the roads areas described above.
The area of lost coverage described above is referred to herein as the "targeted area".
A substantial hardship will result with the decommissioning of AT&T’s site CT5092, removing coverage and service to residents and commuters in Bridgeport. The added network traffic load for the serving sectors of the surrounding AT&T sites covering portions of the subject area will place a substantial capacity strain on the network, resulting in further degradation of network quality. The purpose of the proposed CT5100 site is to provide an interim, remedial solution for the subject area.
4. AT&T 3G Network Coverage Objective
While AT&T holds licenses in the 700 MHz, 800 MHz (Cellular), 1900 MHz (PCS) and 2300 MHz (WCS) bands, the 3G network analysis of this report focuses on the 1900 MHz UMTS coverage since it is this layer that is most impacted by the decommissioning of CT5092.
In this instance, the extent of the coverage gap to be filled is defined by the coverage lost with the decommissioning of AT&T’s site. This affected area is represented in Attachment 2: “1900 MHz UMTS Coverage without CT5092 Site” (CT5092 Decommissioned). As shown by the coverage statistics presented in Table 1 below, the proposed facility (CT5100) will provide substantial fill-in coverage for much of the affected area.
Table 1: Estimated Coverage Lost & Recovered Statistics
2 Population figures are based upon 2010 US Census Block Data
C Squared Systems, LLC 2 September 28, 2015
AT&T CT5991
Included with this report are Attachments 1-3, which are explained below to help describe AT&T’s 3G network coverage in and around Bridgeport, and the immediate need for the proposed facility.
• Attachment 1: “Existing 1900 MHz UMTS Coverage” (Current AT&T Network) depicts 1900 MHz UMTS coverage from the existing sites.
• Attachment 2: “1900 MHz UMTS Coverage without CT5092 Site” shows how decommissioning this site would create a significant coverage gap for this area of Bridgeport. Table 1 provides the details of this lost coverage.
• Attachment 3: “ Composite 1900 MHz UMTS Coverage with Proposed Site” shows the composite coverage from the proposed site when integrated into the network. Table 1 provides the details of this replacement coverage.
Due to terrain characteristics and the distance between the targeted coverage area and the existing sites, AT&T’s options to provide a remedial solution in this area are quite limited (maps of the terrain in this area and the distance to neighboring AT&T sites from the proposed site are included as Attachments 4 & 5, respectively.)
AT&T’s network requires a deployment of antennas throughout the area to be covered. These antennas are connected to receivers and transmitters that operate in a limited geographic area known as a “cell.” AT&T’s wireless network, including their wireless handsets and devices, operate by transmitting and receiving low power radio frequency signals to and from these cell sites. The signals are transferred to and from the landline telephone network and routed to their destinations by sophisticated electronic equipment. The size of the area served by each cell site is dependent on several factors, including the number of antennas used, the height at which the antennas are deployed, the topography of the land, vegetative cover and natural or man-made obstructions in the area. As customers move throughout the service area, the transmission from the portable devices is automatically transferred to the AT&T facility with the best connection to the device, without interruption in service provided that there is overlapping coverage from the cells.
5. AT&T 4G LTE Network Coverage Objective
As noted in section 2, AT&T provides digital voice and data services using 3rd Generation (3G) UMTS technology in the 800 MHz and 1900 MHz frequency band, and is in the midst of deploying advanced 4th Generation (4G) services over LTE technology in the 700 MHz and 1900 MHz frequency bands as allocated by the FCC. As part of their network expansion and ongoing technology advancements in Connecticut and elsewhere in the Country, the 4G LTE network rollout will be built on the existing 3G data services that utilize UMTS technology.
The focus of the following section is AT&T’s 4G LTE network in the 700 MHz and 1900 MHz frequency bands.
C Squared Systems, LLC 3 September 28, 2015
AT&T CT5991
Table 2 below lists the coverage statistics compiled for the AT&T’s 700 MHz and 1900 MHz 4G LTE network with the deployment of the Proposed Site.
Incremental Coverage from Proposed Site (700 MHz)
Incremental Coverage from Proposed Site (1900 MHz)
Population:3 (≥ -83 dBm) 8,013 (≥ -86 dBm) 9,339
(≥ -93 dBm) 33 (≥ -96 dBm) 4,542
Area (mi2): (≥ -83 dBm) 0.95 (≥ -86 dBm) 0.98
(≥ -93 dBm) 0.05 (≥ -96 dBm) 0.55
Roadway (mi): Main: 0.13 Main: 3.21
Secondary: 0.38 Secondary: 5.94
Total: 0.51 Total: 9.15
Table 2: Coverage Statistics
Also included in this report are Attachments 4 through 11, which are explained below to help describe AT&T’s 4G network deployment in and around Bridgeport, and the need for the proposed facility.
• Attachment 4: 3D Terrain Map details the terrain features around the area of deficient service being targeted by the Proposed site in Bridgeport. These terrain features play a key role in determining site designs and dictating the unique coverage achieved from a given location. This map is included to provide a visual representation of the ridges and valleys that must be considered when siting a wireless facility. The darker green and blue shades correspond to lower elevations, whereas the yellow and red shades indicate higher elevations.
• Attachment 5: Map of Distance to Neighbor Sites – Bridgeport provides an overview of AT&T’s network of sites in the area, with distances shown from the Proposed Bridgeport site to the existing sites in the surrounding area.
• Attachment 6: Neighbor Site Data and Distance to Proposed Site provides site specific information of existing neighboring sites used to perform the coverage analyses provided in Attachments 1 through 10.
• Attachment 7: “1900 MHz LTE Coverage without CT5092 Site” shows how decommissioning this site would create a significant coverage gap for this area of Bridgeport
• Attachment 8: “ Composite 1900 MHz LTE Coverage with Proposed Site” shows the composite coverage from the proposed site when integrated into the network.
• Attachment 9: “700 MHz LTE Coverage without CT5092 Site” shows how decommissioning this site would create a significant coverage gap for this area of Bridgeport
3 Population figures are based upon 2010 US Census Block Data
C Squared Systems, LLC 4 September 28, 2015
AT&T CT5991
• Attachment 10: “ Composite 700 MHz LTE Coverage with Proposed Site” shows the composite coverage from the proposed site when integrated into the network
• Attachment 11: Connecticut DOT Average Annual Daily Traffic Data – Bridgeport shows the available vehicular traffic volume data for the subject area from the Connecticut Department of Transportation. This data shows as many as 16,900 vehicles per day passing through Lindley Street near the intersection with Capitol Avenue and as many as 13,800 vehicles per day passing through North Avenue near the intersection with Main Street.
6. Conclusion
AT&T has identified an area of deficient coverage affecting a significant portion of Bridgeport CT, including key traffic corridors through the residential areas of the Town. The proposed Bridgeport Proposed facility will bring the needed fill-in coverage to significant portions of State Highway 8, State Highway 127, Route 1, Main Street, Capitol Ave, Lindley Street, Island Brook Avenue, Huntington Road, Nobile Avenue and the residential neighborhoods in the vicinity of these roads, all of which will be impacted by the decommissioning of AT&T’s existing site CT5092.
No existing structures were identified and available that would be able to satisfy the coverage requirements needed for this area.
As discussed in this report and depicted in the attached plots, the proposed interim AT&T site will provide a substantial portion of the coverage being lost to the “target Area” while maintaining effective connectivity to the rest of AT&T’s existing network and, facilitate the transparent migration from its 3G to 4G network.
7. Statement of Certification
I certify to the best of my knowledge that the statements in this report are true and accurate.
B. Future Carriers –Future wireless carriers to be determined.
III. ENGINEERING ANALYSIS AND CERTIFICATION:
The tower will be designed in accordance with American National
Standards Institute TIA/EIA-222-F and G “Structural Standards for Steel
Antenna Towers and Antenna Support Structures” and the 2003
International Building Code with 2005 Connecticut Amendment. The
foundation design would be based on soil conditions at the site. The
C&F: 2899662.1
final details of the tower and foundation design will be provided as part
of any final Siting Council Development & Management Plan.
C&F: 1287916.1
ATTACHMENT 4
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
PROJECT INFORMATION:
SHEET INDEX
GENERAL NOTES
SCOPE OF WORKAERIAL MAP
UNDERGROUND SERVICE ALERT
SITE TYPE: PERMANENT TOWER INSTALLATION
PROJECTSITE
PROJECTSITE
TOPOGRAPHIC MAP
SITE NUMBER: CT5020 SITE NAME: EVERGREEN STREET
LEGEND
SIGNATURE
SITE NOTES
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
LEGEND
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
LEGEND
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
SITE PLAN
COMPOUND DIMENSION LAYOUT
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
PROPOSED EQUIPMENT SHELTER PLAN
SHELTER ELEVATION DETAIL
GENERATOR DETAIL
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
ICE BRIDGE DETAIL
CHAIN LINK FENCE DETAIL
BOLLARD DETAIL
220 EVERGREEN STREETBRIDGEPORT, CT 06606
BLUE SKY TOWERS, LLC158 MAIN STREET, SUITE 2, NORFOLK,MASSACHUSETTS 02056
COMPOUND SURFACE DETAIL
HAYBALES / SILT FENCE DETAIL
TYPICAL DIRECT JOINT SERVICE
BURIED CONDUIT DETAIL
p: 978.557.5553 f: 978.336.5586 a: 1600 Osgood Street, Building 20 North, Suite 2-101, N. Andover, MA 01845
p: 413.588.8139 f: 413.517.0590 a: 116 Pleasant Street, Ste 302, Easthampton, MA 01027
1-A CERTIFICATION Client: Blue Sky Towers, LLC 158 Main street, Suite 2, Norfolk, MA 062056 Site Number: CT-5020 Site Name: Evergreen Street Site Address: 220 Evergreen Street, Bridgeport, CT Type of Survey: X GPS Survey X Ground Survey Horizontal Datum: NAD83 - expressed in degrees of Latitude and Longitude Vertical Datum: NAVD88 - expressed in feet Above Mean Sea Level (AMSL) Structure Type: Self-Support Tower X Monopole Tower Guyed Tower Wood Pole Water Tank Smoke Stack Roof Top Church Steeple Temporary Site Silo Other Center of Structure: Latitude 41° 11’ 52.00” N Longitude 73° 11’ 26.49” W Ground Elevation: 13’ (AMSL) 0’ (AGL ) Top of Monopole: 148’ (AMSL) 135’ (AGL) Center of Proposed AT&T Antennas: 143’ (AMSL) 130’ (AGL) Certification: I certify that the latitude and the longitude are accurate to within +/- 20 feet horizontally, and
that the ground elevation is accurate to within +/- 3 feet vertically. The horizontal coordinates are based upon the North American Datum of 1983 (NAD 83) and are expressed in degrees of Latitude and Longitude. The elevations are based on the North American Vertical Datum of 1988 and are expressed in feet Above Mean Sea Level (AMSL).
Signature: Charles G. Gidman, RPLS Date: June 12, 2015
C&F: 2929003.1
TOWAIR Determination Results
A routine check of the coordinates, heights, and structure type you provided indicates that this structure does not require registration.
*** NOTICE ***
TOWAIR's findings are not definitive or binding, and we cannot guarantee that the data in
TOWAIR are fully current and accurate. In some instances, TOWAIR may yield results that differ
from application of the criteria set out in 47 C.F.R. Section 17.7 and 14 C.F.R. Section 77.13. A
positive finding by TOWAIR recommending notification should be given considerable weight. On
the other hand, a finding by TOWAIR recommending either for or against notification is not
conclusive. It is the responsibility of each ASR participant to exercise due diligence to
determine if it must coordinate its structure with the FAA. TOWAIR is only one tool designed to
assist ASR participants in exercising this due diligence, and further investigation may be
necessary to determine if FAA coordination is appropriate.
DETERMINATION Results
PASS SLOPE(100:1): NO FAA REQ-RWY MORE THAN 10499 MTRS & 6697.67 MTRS (6.69770 KM) AWAY
Type C/R Latitude Longitude Name Address Lowest Elevation
Type C/R Latitude Longitude Name Address Lowest Elevation
(m) Runway Length
(m)
AIRP R 41-09-
58.00N
073-08-
6.00W
IGOR I
SIKORSKY MEMORIAL
FAIRFIELD
BRIDGEPORT, CT
1.7 1451.2
Your Specifications
NAD83 Coordinates
Latitude 41-11-52.0 north
Longitude 073-11-26.5 west
Measurements (Meters)
Overall Structure Height (AGL) 41.1
Support Structure Height (AGL) 41.1
Site Elevation (AMSL) 4
Structure Type
MTOWER - Monopole
Tower Construction Notifications Notify Tribes and Historic Preservation Officers of your plans to build a tower.
C&F: 1287916.1
ATTACHMENT 5
C&F: 2899663.1
ATTACHMENT 5
ENVIRONMENTAL ASSESSMENT STATEMENT
I. PHYSICAL IMPACT
A. WATER FLOW AND QUALITY
The tower site is located on an undeveloped Parcel of property that is
vacant, but used as part of Chapin & Bangs materials storage. The
lease area and proposed areas of disturbance are located along the lot
frontage on Evergreen Street. The location of the permanent tower site
is outside of the 100 year flood zone located on the lot. There are no
on-site wetlands, therefore, no direct impact to any wetlands or
watercourses are anticipated as a result of the tower site construction.
Storm water will be managed with Best Management Practices to be
implemented during construction. (DEEP Sedimentation and Erosion
Control manual 2002 and the ConnDot Drainage Manual.)
B. AIR QUALITY
Under ordinary operating conditions, the equipment that would be used at
the proposed facility would emit no air pollutants of any kind. An
emergency diesel fuel generator with secondary containment systems will
comply with Connecticut Department of Energy and Environmental
Protection ("CTDEEP") air standards for such facilities.
C. LAND
The overall area of disturbance is less than 10% of the one acre lot
which is already cleared. Minimal grading will be needed to develop the
permanent tower site. The remaining land of the lessor would remain
C&F: 2899663.1
undisturbed by the construction and operation of the facility and continue
to be used for materials storage.
D. NOISE
The equipment to be in operation at the facility would not emit noise
other than that provided by the operation of the installed heating, air-
conditioning and ventilation system. Some construction related noise
would be anticipated during facility construction, which is expected to take
approximately four to six weeks. Temporary power outages could involve
sound from the emergency generator which would be cycled once
weekly.
E. POWER DENSITY
The cumulative worst-case calculation of power density from AT&T’s
operations at the facility would be 3.98% of the MPE standard. Attached
is a copy of a Power Density Report for the facility.
F. VISIBILITY
The attached Visibility Analysis includes an evaluation of the anticipated
viewshed for the monopole tower. Potential visibility was assessed within
using a computer-based, predictive view shed model that was field
verified. Areas from where the proposed Facility would be visible are
generally between local buildings and trees within a ¼ mile of the project
site. Visibility beyond this point will be limited to brief glimpses between
and/or above intervening structures. When visible, the project will be
seen within the context of the existing industrial landscape. Existing
manufacturing, warehousing, and commercial buildings dominate all views
in this section of the City. Urban conditions including roadways, heavy
traffic, overhead utility infrastructure, street lighting, road and commercial
C&F: 2899663.1
signage and other elements of the city landscape are common visual
features in this part of the City. The proposed tower is visually
consistent and does not create an adverse visual impact. No schools or
licensed child day care centers are located within 250’ of the site.
II. SCENIC, NATURAL, HISTORIC & RECREATIONAL VALUES
The Connecticut State Historic Preservation Officer (“SHPO”) and the
Connecticut Department of Energy and Environmental Protection
("CTDEEP") were contacted. No direct impact to a historical or natural
resource has been identified and no impacts to threatened or endangered
species were identified. The site is also under evaluation in accordance
with the FCC’s regulations implementing the National Environmental
Policy Act of 1969 (“NEPA”) and no known impacts to federally
recognized environmental resources are known at this time.
C&F: 1287916.1
ATTACHMENT 6
C&F: 1287916.1
ATTACHMENT 7
August 24, 2015
Connecticut Siting Council Subject: New Cingular Wireless PCS, LLC (“AT&T”) – (CT5100) – 220 Evergreen Street, Bridgeport, CT
Dear Connecticut Siting Council:
C Squared Systems has been retained by New Cingular Wireless PCS, LLC (“AT&T”) to investigate RF Power Density levels for the AT&T antenna arrays, to be installed on the proposed monopole, to be located at 220 Evergreen Street, Bridgeport, CT Calculations were done in accordance with FCC OET Bulletin 65. These worst-case calculations assume that all transmitters are simultaneously operating at full power and that there is 0 dB of cable loss. The calculation point is 6 feet above ground level to model the RF power density at the head of a person standing at the base of the tower. Due to the directional nature of the proposed AT&T antennas, the majority of the RF power is focused out towards the horizon. As a result, there will be less RF power directed below the antennas relative to the horizon, and consequently lower power density levels around the base of the tower. Please refer to the Attachment for the vertical patterns of the proposed AT&T antennas. The calculated results below include a nominal 10 dB off-beam pattern loss to account for the lower relative gain directly below the antennas.
Total Summary: Under worst-case assumptions, RF Power Density levels for the proposed AT&T antenna arrays will not exceed 3.98%1 of the FCC MPE limit for General Public/Uncontrolled Environments. Sincerely,
Daniel L. Goulet C Squared Systems, LLC
1 The total %MPE is a summation of each unrounded contribution. Therefore, summing each rounded value may not reflect the total value listed in the table.
Daniel L. Goulet C Squared Systems, LLC 65 Dartmouth Drive Auburn, NH 03032 603-644-2800 [email protected] C Squared Systems, LLC
Attachment: AT&T’s Antenna Data Sheets and Electrical Patterns
750 MHz
Manufacturer: CCI Products Model #: HPA-65R-BUU-H8
Figure 8bSimulated ViewViewpoint 7 - River Street near Meriam Street
C&F: 1287916.1
ATTACHMENT 9
Connecticut Department of
ENERGY & ENVIRONMENTAL P R O T E C T I O N
July 13, 2015 Christopher Bond IVI Telecom Services, Inc. 4 West Red Oak Lane White Plains, NY 10604 [email protected] Project: New Telecommunications Facility for AT&T CT-5020/Evergreen Street Located at 220 Evergreen Street in Bridgeport NDDB Determination No.: 201504675 Dear Christopher Bond, I have reviewed Natural Diversity Data Base (NDDB) maps and files regarding the area delineated on the map provided for the proposed New Telecommunications Facility for AT&T CT-5020/Evergreen Street Located at 220 Evergreen Street in Bridgeport, Connecticut. I do not anticipate negative impacts to State-listed species (RCSA Sec. 26-306) resulting from your proposed activity at the site based upon the information contained within the NDDB. The result of this review does not preclude the possibility that listed species may be encountered on site and that additional action may be necessary to remain in compliance with certain state permits. This determination is good for one year. Please re-submit an NDDB Request for Review if the scope of work changes or if work has not begun on this project by July 13, 2016. Natural Diversity Data Base information includes all information regarding critical biological resources available to us at the time of the request. This information is a compilation of data collected over the years by the Department of Energy and Environmental Protection’s Natural History Survey and cooperating units of DEEP, private conservation groups and the scientific community. This information is not necessarily the result of comprehensive or site-specific field investigations. Consultations with the Data Base should not be substitutes for on-site surveys required for environmental assessments. Current research projects and new contributors continue to identify additional populations of species and locations of habitats of concern, as well as, enhance existing data. Such new information is incorporated into the Data Base as it becomes available. Please contact me if you have further questions at (860) 424-3592, or [email protected] . Thank you for consulting the Natural Diversity Data Base. Sincerely,
Dawn M. McKay Environmental Analyst 3
79 Elm Street, Hartford, CT 06106-5127 www.ct.gov/deep